Interpretation Response #25-0026
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Entegris Inc.
Individual Name: James McManus
Location State: CT Country: US
View the Interpretation Document
Response text:
Jim V. McManus
Sr. Principal Engineer
Dangerous Goods Safety Advisor (DGSA)
Entegris Inc.
7 Commerce Drive
Danbury, CT 06810
Reference No. 25-0026
Dear Mr. McManus:
This letter is in response to your March 5, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the proper shipping name (PSN) for "UN2036, Xenon, compressed" as listed in the § 172.101 Hazardous Materials Table (HMT). Specifically, you ask for clarification regarding the appropriate use of the qualifying word "compressed" in association with the PSN for transport of xenon based on your understanding the word was removed under the rulemaking "Harmonization With the United Nations Recommendations, International Maritime Dangerous Goods Code, and International Civil Aviation Organization's Technical Instructions" (HM-215E).
Your questions are paraphrased and answered below:
Q1. For domestic shipments, is "Xenon, compressed" the PSN for UN2036?
A1. Yes. The PSN for xenon (UN2036) was revised to read "Xenon, compressed" in the § 172.101 HMT for consistency with PSNs for other compressed gases (i.e., other inert gases) in the rulemaking "Hazardous Materials: Revision to Requirements for the Transportation of Battery-Powered Devices; and Harmonization With the United Nations Recommendations, International Maritime Dangerous Goods Code, and International Civil Aviation Organization's Technical Instructions" (HM-224D/HM-215J) that postdated final rule HM-215E. Therefore, for purposes of the HMR, the PSN for xenon (UN2036) includes the qualifier "compressed."
Q2. As authorized by § 171.22(a), may a shipment of xenon offered for transport in accordance with the International Maritime Dangerous Goods Code for export from the United States use the PSN "Xenon" for UN2036, instead of "Xenon, compressed?"
A2. Yes.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards and Development Branch
Standards and Rulemaking Division
§ 172.101, § 171.22(a)